[ Bringing of appeals against decisions of HMRC U.K.
26F(1)An appeal under paragraph 26 is to be made to the tribunal before—U.K.
(a)the end of the period of 30 days beginning with the date of the document notifying the decision to which the appeal relates, or
(b)if later, the end of the relevant period (within the meaning of paragraph 26C).
(2)But that is subject to sub-paragraphs (3) to (5).
(3) In a case where HMRC are required to undertake a review under paragraph 26B—
(a)an appeal may not be made until the conclusion date, and
(b)any appeal is to be made within the period of 30 days beginning with the conclusion date.
(4) In a case where HMRC are requested to undertake a review in accordance with paragraph 26D—
(a)an appeal may not be made—
(i) unless HMRC have decided whether or not to undertake a review, and
(ii) if HMRC decide to undertake a review, until the conclusion date; and
(b)any appeal is to be made within the period of 30 days beginning with—
(i) the conclusion date (if HMRC decide to undertake a review), or
(ii) the date on which HMRC decide not to undertake a review.
(5)In a case where paragraph 26E(8) applies, an appeal may be made at any time from the end of the period specified in paragraph 26E(6) to the date 30 days after the conclusion date.
(6)An appeal may be made after the end of the period specified in sub-paragraph (1), (3)(b), (4)(b) or (5) if the tribunal gives permission to do so.
(7)In this paragraph “conclusion date” means the date of the document notifying the conclusions of the review.]